Permanent Establishment rules UAE, with new CT on Companies

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If you are talking‍ about in-app purchases Google treats those as copyright royalties.

This guy is experiencing the same⁠ problem with his Android app: ATO Community
 
Because everybody would leave and UAE wants people to stay.

Depends on what you do, but not everybody operates through their FZCO.

Not really, some like ENBD are quality⁣ banks.

Both are correct. Again depends on what you do.︀

Theres a lot of countries on Earth with laws and rules on paper and thats︁ nice and all but then you go there and reality is a completely different story.︂ Not everywhere is like Germany/Sweden for example.
 
Look i understand that but honestly, where would people go if they really will start‍ cracking down on people managing offshore companies from UAE?
 
tbh no idea but Qatar maybe?

What im trying to say is that Emirates is making‍ big efforts into making people stay at the family level. They wanna break the years⁠ long trend of people going there for a few years to then go back to⁤ their home country.

At the end of the day its a soulless place in the⁣ middle of the desert, tons of fun yeah but not the type of place most⁢ people look to relocate initially so if they start screwing the tax incentives... why be︀ there?
 
The only answer that comes to mind is that‍ AdMob operates in a different way than AdSense and that's why they are paying you⁠ with royalties.

Because even paying 9% it's still a better place than Malta (for example)⁤ where you would pay 5% but you will live in an overcrowded polluted hell or⁣ some Caribbean island / secluded LATAM country where your brain will shrink because the only⁢ thoughts going through the mind of locals is how to get food, beer and sex︀ (not necessarily in that order).
 
Yes. they will not target you as this will simply means⁣ UAE's death as a business heaven.
Correct.
people will flee.
it's a mix of the above and plus other reasons.︄
UAE companies are expensive, that's the reality, so if your turnover isn't high enough, it︅ doesn't make any financial sense to operate from a FZCO.
Also, it's not every one's︆ cup of tea and some financial institution's won't do business with UAE based companies thanks'︇ to FATF grey list.
and some clients specially in the US - and if your︈ business is B2C - will absolutely refuse to deal with any middle eastern company.

Once Your average joe from southern Indiana sees a Dubai company mentioned in the footer of︉ your store/website, he will only think "Muslims, dessert, 9/11, sharia law, brown guys" and he︊ will absolutely go "america #1, muh freedum, muh guns, bla bla bla" and won't deal︋ with you, I'm not saying that these actions are fair or correct, but this is︌ just the reality that we live in.
and as other's mentioned, with a US LLC,︍ your banking options are better "but only in the US and in USD", you will︎ have better spreads, better banking opportunities, more opportunities to scale your business globally and much️ more.
Honestly, no where, but to be objective, they will likely go to a territorial country⁠ or a country whom tax office doesn't give a flying f (Malaysia, Thailand...etc)
maybe, Qatar had a great opportunity⁣ to through themselves out there and tell the world what can they offer through the⁢ world cup. only time will tell if they utilize this exposure the right way.
Correct. and Russians elites and their families are already making good use of︂ this trend. some higher ups like it, others don't want the UAE to be︃ a playground for a certain group, they want to maintain a neutral stance with everybody.︄ and be the "USA" of the middle east in terms of cultural diversification.
that was the thing of the past, they want to become a futuristic, capitalist︉ county with great opportunities for the right opportunists. So, make use of that and grow︊ yourself and your business/es further.

UAE is here to stay, once they normalized their relation︋ with Israel and money started flowing from UAE to Israel and viceversa, it was literally︌ game over. Money talks and Israel has that much power over the US. Israelis don't︍ want to jeopardize their relationship with the UAE and having to face the Iranians all︎ alone. UAE played their cards right, whether you agree with these policies/their politics or not,️ that's a smart move. and both parties are hellbent to expand these relationships even further.‌
See the signs and make use of them. be an opportunist.
 
Fair enough but would you say that banking options would still be better if︇ a US LLC is owned by a UAE resident (either natural or legal person) than︈ operating a multicurrency account in UAE?

Will Mercury, Relayfi and all the usual suspects open︉ you a bank account when they will hear that UBO is a UAE resident?

I guess since UAE is on the FATF list it is difficult / expensive to receive︊ USD directly in UAE
 
imo it aint that US⁠ banks are 'better' per se. Its just that some people will see a SWIFT code⁤ from a bank in the Middle East and will just refuse to transact with you.⁣

There're some very solid banks in UAE, but its a matter of perception.

If you⁢ dont deal with clients directly, UAE banks are fantastic.
 
It's not about which one⁠ is "better", it's about how are you gonna use them.
US EMIs/banks serves you better⁤ when dealing in USD with US clients/services. for other purposes (e.g. investments) UAE banks are⁣ more than fine.
Yes. I've no problem opening with novel, mercury, brex..etc with My UAE residency.
No, some banks have some delays,︂ but your money is usually credited within 1-3 business days.
 
0 problems faced. It is really a⁢ breeze there.
Opening UAE business banks is like a magnitude harder as a Dubai resident.︀

You can use ACH in US (which is very easy for sending cash inside US,︁ just 2 numbers needed and no cumbersome swift), some ecom options like shopify pay etc.︂ You can setup Interactive brokers etc.

Usd wires are also easy to get. IB usually︃ credits within hours on UAE banks and others need a day or two but that︄ can happen even with Fedwire and sending inside US.
 
I agree on what MiddleEuroAsia states, they won't bother you and⁣ even some of them legally you don't have to pay any tax on your foreign⁢ income.

If you employ people or do business in those countries itself, I do recommend︀ to fully comply with the part of business/income you derive in that country (by employing︁ people or doing local business) and pay correctly all taxes as well don't let any︂ outside money flows go through that local business.

In the PH you have no crs︃ and 100pct bank secrecy where even the government or any instance by court order can't︄ access your account balance / transactions unless you are a terrorist or child trafficker.

So if you are a resident in one of the SEA countries mentioned, be a resident︅ there, live there most of the time and cut all ties with your citizenship country︆ you are good.
 
From US "Banking" (Mercury, Relay etc.) point⁢ of view it doesn't make a difference according to what we have seen however some︀ clients reporting they get input from US based CPA's that a FZCO as US LLC︁ Shareholder can trigger C-CORP requirements.

Still - everyone seems to get away with it -︂ even the guys with almost 100% US Sourced income from US clients are not facing︃ any issues.

We as DLS Dubai recommend our clients having a FZCO setup with us︄ - to form a disregarded passthrough single member US LLC with themselves as only company︅ owner with Dubai Residence - to faciliate US payments from foreign Comapnies having just a︆ US based bank account as well - famous example: Binance Account under FZCO makes deposits︇ and withdrawals to the Binance entity based on the Seychelles holding a Signature US Bank︈ Account. In this way it's impossible to trigger anything on the US side.

However meanwhile︉ you have "Mercury like"finanical institutions onboarding directly the FZCO and clients with existing LLC's starting︊ shifting over the whole payment processing directly to the FZCO while for the reputation they︋ claim "XXX webiste - concept and design by XXX LLC - payment and collecting by︌ XXX FZCO" works perfectly fine and got confirmed from several US based CPA's / Lawyers︍ we are working with.

With this scheme the upcoming 9% CT are passed by and︎ our clients are happy to remain 0% Tax even with heavy US business exposure.

Yes - the peanut counters are still not happy because the FZCO can't collect at the️ same % rate with payment gateways like the US LLC - however this is the‌ cost of doing 0% Tax Offshore Business.
 
Hi @MiddleEuroAsia would that scheme work with a UK LLP instead of⁣ a US LLC? Basically me and my FZCO will be the shareholders of the UK⁢ LLP and in that way I would be able to get a business bank account︀ in Europe and decent rates for payment processing. Stripe and PayPal are a total ripoff︁ for businesses in the UAE and I already had a Greek client refusing to pay︂ an invoice made by a company in an Arabic state as you mentioned.
 
It would probably be a bit of a challenge to get a payment processor to︀ accept such a setup.
Other than that I completely agree with @MiddleEuroAsia - he was︁ way ahead of all this here.

But where do you find a manager you can︂ trust? And in a jurisdiction that won't cause trouble with bank accounts?
 
With the new laws in UAE, even this set up would now⁣ incur 9% tax and accounting/auditing requirements, correct?

US LLC/UK LLP owner living in territorial taxation⁢ countries with no enforcement of PE would be ideal to avoid all the complexity of︀ UAE taxation. Thailand I think is the easiest, with easy immigration (Elite Visa). I spent︁ some time in Thailand and absolutely no one on Elite visa is asked to file︂ taxes if not remitting money in the same year.

Of course, a lot depends on︃ personal preferences. 9% tax isn't a lot esp with all the ways you can lower︄ your taxes for the next few years. People have been discussing personal income tax in︅ UAE down the road etc..so if long term tax optimization is what one is after,︆ maybe look outside of UAE.
 
Not necessarily. Holding companies are exempt‍ from corporate tax, not sure if they'd still have to prepare accounts.
 
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